Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
c/o General Delivery at:
2509 North Campbell Avenue
Tucson, Arizona state
In Propria Persona
All Rights Reserved
Without Prejudice
PIMA COUNTY CONSOLIDATED JUSTICE COURT
Paul Andrew Mitchell, ) Case Number #CV-97-3438
Plaintiff )
) ANSWER TO COUNTERCLAIM
v. )
)
Neil and Evelyn Nordbrock, )
Defendants )
___________________________)
COMES NOW Paul Andrew Mitchell, Sui Juris, Citizen of Arizona
state and Plaintiff in the above entitled matter (hereinafter
"Plaintiff"), to provide this, Plaintiff's ANSWER TO COUNTERCLAIM
by Defendants.
I
Plaintiff specifically denies each and every allegation in
the Counterclaim, whether numbered or unnumbered.
II
Plaintiff specifically denies the allegation that Plaintiff
committed "Defamation Per Se" against Defendants.
III
Plaintiff specifically denies the allegation that Plaintiff
committed "Tortious Interference with Business Advantage and/or
Contractual Relationship" against Defendants.
Answer to Counterclaim:
Page 1 of 3
IV
Plaintiff relies upon the truth to support Plaintiff's
verified complaint against Defendants, and Plaintiff's defense
against the Counterclaim of Defendants.
Wherefore, Plaintiff requests judgment against Defendants:
(1) awarding to Plaintiff the exact amount specified in the
original Complaint;
(2) awarding legal fees pursuant to A.R.S. 12-341.01(A) and
(C) and 349;
(3) awarding recoverable costs pursuant to A.R.S. 12-341;
(4) dismissing Defendants' Counterclaim with prejudice and
denying all relief requested therein;
(5) awarding such other and further relief as the Court
deems just and proper.
OBJECTION TO REPRESENTATION
Plaintiff hereby enters a permanent, standing objection to
the conflict of interest which is now evident in Defendants'
representation in this honorable Court by Mr. Lawrence E. Condit,
for reasons which have already been filed in Plaintiff's
AFFIDAVIT OF DEFAULT AND OF PROBABLE CAUSE IN RE LAWRENCE E.
CONDIT, which is incorporated by reference as if set forth fully
herein.
Dated: April 23, 1997
Respectfully submitted,
/s/ Paul Andrew Mitchell
_____________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
All Rights Reserved without Prejudice
Answer to Counterclaim:
Page 2 of 3
PROOF OF SERVICE
I, Paul Andrew Mitchell, Sui Juris, hereby certify, under penalty
of perjury, under the laws of the United States of America,
without the "United States," that I am at least 18 years of age,
a Citizen of one of the United States of America, and that I
personally served the following document(s):
ANSWER TO COUNTERCLAIM
by placing one true and correct copy of said document(s) in first
class United States Mail, with postage prepaid and properly
addressed to the following:
Neil and Evelyn Nordbrock
c/o 6642 E. Calle de San Alberto
Tucson, Arizona state
Executed on April 23, 1997
/s/ Paul Andrew Mitchell
_____________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
All Rights Reserved without Prejudice
Answer to Counterclaim:
Page 3 of 3
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